Analyses of proposals to amend

Ref. CoP13 Prop. 37 Inclusion of Hoodia spp. in Appendix II, designating all parts and derivatives except those bearing the label ‘Produced from Hoodia spp. material obtained through controlled harvesting and production in collaboration with the CITES Management Authorities of Botswana, Namibia and South Africa under agreement no. BW/NA/ZA xxxx’. Proponents: Botswana, Namibia and South Africa.

Summary: Hoodia spp. are slow-growing, perennial, spiny succulent plants. They occur in a wide range of arid habitats in southern Africa, typically on arid gravel or shale plains. The genus is generally considered to consist of 14 species and four infraspecific taxa. A broader taxonomic interpretation of the genus recognises 26 species. Detailed information on the distribution and population status of individual taxa is limited. The proposal states that ten of the 16 taxa assessed have been classified as threatened according to the IUCN Red List Categories and Criteria, with four taxa classified as Vulnerable in 2002. Strong commercial interest in the genus results from the isolation and patenting of an active ingredient (P57) which acts as an appetite suppressant. The active ingredient has been isolated from H. gordonii, which is abundant and widespread in Namibia and South Africa. It is thought likely that the active ingredient may also be present in a number of other species, some of which have more limited and patchy distributions. These may be vulnerable to over-collection. Hoodia spp. are legally protected in most countries of occurrence, and the trade is regulated by national legislation in Botswana, Namibia and South Africa, but there is evidence of illegal trade, which seems to be a growing problem. The proponents seek inclusion of the genus in Appendix II to establish a standardized international trading framework and monitoring regime. The proposed annotation if adopted would imply that only the certified sustainable trade from three range States would be exempt from the provisions of the Convention. Trade from Zimbabwe or any non-certified trade from Botswana, Namibia and South Africa would be subject to the provisions of the Convention as would imports into Parties from Angola (a non-Party). Trade in specimens of Hoodia grown in countries outside the region, and their parts and derivatives, would also be subject to CITES controls. Details of how the proposed controlled harvesting and production operations to be developed in collaboration with the CITES Management Authorities of Botswana, Namibia and South Africa might operate are not given in the proposal. Parties are therefore asked to consider a new form of listing on the basis of limited information about how this would work. Analysis: Hoodia spp., are at risk in the wild because of their perceived value on the international market as a source of appetite suppressants. The species from which the active pharmaceutical ingredient has been identified, H. gordonii remains widespread and abundant but there is evidence of damage to wild populations from collectors. Although not currently considered to be threatened, this species may meet Resolution Conf. 9.24 Annex 2a, criterion B i) in that harvesting of specimens from the wild for international trade may have a detrimental impact on the species by exceeding, over an extended period, the level that can be continued in perpetuity. Other species of Hoodia have much more restricted ranges and some are considered threatened in the wild. Several of these may be vulnerable to over-harvesting. In view of the similarity of all species, the remaining species are likely to meet the criteria in Annex 2b of Resolution Conf. 9.24 for inclusion in Appendix II. Three of the range States for this species wish to use CITES Appendix II to help manage wild populations harvested for international trade in a novel way. From the information provided in the listing proposal it is difficult to understand how the proposed annotation would work in practice. No indication is given in the proposal regarding how the proponents intend the label to be applied or which agencies would be responsible for granting authorisation to use it. Furthermore, the label implies that there will be a mutually binding agreement on “controlled harvesting and production” for Hoodia among the three proponent countries. Information on how this would operate within the context of CITES would be beneficial for the Parties in considering this proposal. Information provided and statements made by Information provided and statements made by proponents in the Supporting Statement proponents in the Supporting Statement Taxonomy
The family for this genus is given as Apocynaceae.
Hoodia has previously been included in the family Asclepiadaceae. The two sub-families of the
The proposal does not include a full list of taxa
Asclepiadaceae were transferred to the Apocynaceae in
considered to be included in the genus.2000 (Endress and Bryuns, 2000), because there are a few bridging genera which possess features from each of these families (Plowes, 2004). There is ongoing taxonomic debate about this decision. Müller and Albers, 2002, whilst noting the formal transfer, continue to use the family name Asclepiadaceae. They consider that the genus Hoodia consists of 14 species and four infraspecific taxa. Information provided and statements made by Information provided and statements made by proponents in the Supporting Statement proponents in the Supporting Statement According to Plowes (2004), there may be 26 species in the genus Hoodia, including the so-called “spiny Trichocaulons”. Hybrids are known with Orbea and Tromotriche (Müller & Albers, 2002).
Angola, Botswana, Namibia and South Africa.
Zimbabwe is an additional range State for the genus.
H. gordonii occurs in Botswana, Namibia and South Africa. It does not occur in Angola (Golding, 2004). There is uncertainty about the presence of H. gordonii in Botswana. According to Hargreaves (2004) there is no evidence of the species occurring within the country and the record is based on a mislabelled specimen. IUCN Global Category
Ten of the 16 taxa assessed have been classified as
The 1997 status information given to in the proposal
threatened in the latest Red List assessments. The
appears to be based on the 1997 IUCN Red List of Threatened Plants (Walter and Gillett, 1998). The 2002 status information appears to be based on the information given in the Southern African Plant Red Data H. dregei,H. juttae, H. officinalis subsp. Delaetiana, H. pilifera subsp. annulata, H. pilifera subsp. Pillansii, H. pilifera subsp. pilifera, H. ruschii and H. triebneri.Biological and trade criteria for inclusion in Appendix II B) Harvesting for international trade has, or may have, detrimental impact on population (i) exceeds sustainable yield; (ii) reduces population to potentially threatened level
Little is known about population trends, although
Although Hoodia gordonii is widespread, plants are
declines have taken place at various sites. There are
usually in small scattered population pockets, often with
reports that Hoodia spp. have disappeared from parts of
only a few dozen plants in each, or less. They can be
their range due to mining, infrastructure development
easily seen from a distance because of their size, being higher than the surrounding low karroid shrubs and therefore all individuals are likely to be taken by
In addition all species have been subject to collecting by
harvesters, leaving only hidden seedlings to regenerate
succulent collectors. Harvesting for medicinal purposes
has traditionally occurred. Since the isolation of the active ingredient in H. gordonii and the extensive press
Recent observations in the Central Namib, Namibia
coverage projecting the financial value of this,
indicate the removal of larger individuals of H. gordonii
commercial harvesting has become a large potential
by collectors – usually when the plants are in flower and
threat. Although H. gordoniii is abundant and
widespread, collectors cannot always tell the species apart and wild collection is thought likely to impact a
There is no evidence of harvesting of Hoodia spp., in
number of Hoodia spp. Harvesting requires cutting off
the above ground parts of the plants, and it is relatively
Ethnobotanical records suggest that several species in addition to H. gordonii are of interest for appetite suppressing properties namely: Hoodia currorii, Hoodia
To date, levels of trade from Botswana, Namibia and
flava, Hoodia lugardii, Hoodia (Trichocaulon) piliferum,
South Africa have been very limited. No information is
and Hoodia (Trichocaulon) officinale (Wynberg, 2004a).
presented from Angola. There is evidence of illegal trade from the three proponent countries.
The active ingredient known as P57 has been patented, the patent covering six species: H. currorii, H. gordonii,
The potential impact of illegal trade is thought to be very
H. lugardii, H. (Trichocaulon) piliferum, and
high after the patenting of P57 in South Africa.
H. (Trichocaulon) officinale (Wynberg, 2004a). However,
Several species, such as H. gordoniii, occur in very large
the natural product cannot be patented entirely. There is
populations with extensive distributions of over 10 000
therefore no copyright infringement by manufacturing
km2. Others occur in small, isolated patches with a total
and selling any natural products derived from H. gordonii
distribution of less than 1000 km2. No subpopulation of
or other species that should prove to contain P57, even H. pilifera subsp. pillansii is thought to exceed 250
though such products would also naturally contain P57. Medications that are reputed to contain Hoodia material are currently sold widely, particularly in the USA and the Information provided and statements made by Information provided and statements made by proponents in the Supporting Statement proponents in the Supporting Statement UK. Prices vary between USD 39 and USD 70 (90 capsules, 400 mg per capsule). Other information
The extent of illegal trade is unknown, but illegal exports
Very few localities are known where diamond or other
have been reported in all three countries. It is alleged
mineral deposits coincide with Hoodia populations, a
that foreign pharmaceutical companies may have been
small part of the range of H. currorrii at Rossing uranium
obtaining significant amounts of Hoodia through illegal
mine near Swakopmund, Namibia being a notable exception. Overgrazing does not directly impact Hoodia species because most, if not all, species are not normally
Populations have also been declining due to habitat loss
grazed by livestock, but loss of grazeable shrubs could
or degradation caused by mining, development of
eliminate the ‘nurse’ plants that are necessary for
infrastructure, collecting and overgrazing. Several
successful germination and growth of Hoodia spp. The
localities of H. currorrii subsp. lugardi have been lost to
arid habitats required by Hoodia species generally
the combined effects of diamond mining and attack by a
prevent their conversion to arable lands (Plowes, 2004). Poor regeneration in natural populations has been reported. During the years 1996 to 2004, small populations of H. gordonii in the Spitskoppe, Brandberg and Namib Naukluft Park (Central Namib, Namibia) have been visited on various occasions. Juveniles were rarely found and there was evidence of the soft juvenile plants being browsed by game (Strohbach, 2004). Various species have been impacted by local use for food and medicines. Hoodia rustica (sometimes considered a synonym of H.officinalis) is known only from a few localities on rocky hills in South Africa. The last plant at the Vosberg site was found and eaten in 1985. H. flava and H. pilifera are also utilised locally (Plowes, 2004). As early as 1937 it was reported from South Africa that H. (Trichocaulon) pillansi had been “almost exterminated through the zeal of collectors and because of its edible and supposedly medicinal properties”. Formerly, the plant is said to have been fairly frequent, sufficiently so to give its name to one of the hills in the Witteberge, Ngaap Kop (Trichocaulon Hill) (Wynberg, 2004b). Collecting appears to be the main potential threat. For example, the Northern Cape’s Department of Agriculture, Land Reform, Environment and Conservation (DALEC) has reliably learned of Hoodia material being supplied to the international pharmaceutical market without permits. The illegal collection of Hoodia has escalated to such an extent that its future existence may well be ‘under greater threat than ever before (Anon., 2004). Conservation, management and legislation South Africa:Hoodia spp. are protected in the Northern South Africa: The National Biodiversity Act (10 of 2004)
Cape (Environmental Conservation Ordinance No. 19 of
has recently been promulgated. Enforcement, however,
1974). Permits are required for collecting, cultivation,
will only be possible once regulations are in place. This
transport or export. Similar regulations are applied in the
legislation will provide national (including access and benefit sharing agreements) protection and international (including CITES) protection and other requirements for
Western Cape Nature Conservation has permitted
use of plant species such as Hoodiaspp. (TRAFFIC
developing companies to use a limited amount of wild
harvested Hoodia. Permits have been issued to the Council for Scientific and
Zimbabwe: H. lugardii is a specially protected plant in
Industrial Research, which has set up a benefit sharing
terms of the Zimbabwean Parks and Wildlife Act of 1975.
agreement with the local San communities.
Botswana: Harvesting is controlled by the Agricultural Resources Conservation Act [CAP. 35:06] in which Hoodia
is listed as a veld product. Regulations for harvesting of veld
Information provided and statements made by Information provided and statements made by proponents in the Supporting Statement proponents in the Supporting Statement
products were published on 26 March 2004. Harvest permits
are required and harvest areas are inspected by officers
from the Agricultural Resources Board. Hoodia currorii has
been presented to the Board to become legally protected.
Namibia: All Hoodia species are legally protected requiring prior authorization for harvesting and trade. Harvesting is not currently authorized. The country intends to establish a controlled harvesting system. The status of Hoodia spp. has been assessed since 2001 and monitoring as part of a long-term plant conservation programme has been expanded, but funding is limited. Angola: No information. In situ protection: H. gordonii occurs in the central Kalahari and Makgadikgadi National Parks (Botswana), the Ai-Ais/Richtersveld Transfrontier Park (South Africa), the Skeleton Coast Park and a new national park in southern Namibia (the former Sperrgebiet) as well as in several Conservancies. Similar species Hoodia species resemble one another and have been
There are superficially similar species within the family
confused with certain cacti species, such as Trichocerus Apocynaceae (Asclepiadaceae) that occur in the same region as Hoodia spp. Large, flat dish-like flowers are generally a distinguishing feature of Hoodia spp.Artificial Propagation Hoodia spp., are relatively difficult to cultivate, but are
Hoodia spp. are grown by succulent plant enthusiasts
nevertheless used for horticultural purposes.
around the world and are available from specialist nurseries. H. gordonii is considered one of the least
Cultivation trials have been set up in South Africa and
difficult species to grow (Hewitt, 1993).
Namibia, but the plants are not suitable for harvest yet. Hoodia is reported to have been cultivated in Chile and
Other comments Very little work has been conducted on identification of harvest sites and on assessment of damage after harvesting for trade. It is proposed that permission to export will only be given after a full Non-Detriment Finding (NDF) has been concluded. In return for following certain harvest criteria to ensure sustainability, the traders will be allowed to trade without CITES permits. However, legal trade volumes will only be known by the producer country. Ongoing monitoring and periodic re-examination of the NDF seem necessary to control the trade. It will be difficult to track the various purveyors of the plant material, since their identity and their actual involvement are not always clear. The proposed annotation may also create problems in enforcement in importing countries (TRAFFIC East/Southern Africa, 2004). Wynberg (2004a) notes that a standardised international trading framework and monitoring regime for Hoodia needs to be put in place, and needs to ensure that range States capture the economic benefits that accrue from its commercialisation. However, she believes that the implications of the proposal need to be considered more thoroughly before it is approved. Reviewers: P. Downs, J. Golding, B. Hargreaves, B. Huntley, D. Plowes, T. Ron, M. Strohbach, TRAFFIC East/Southern

1.0 Flora The flora surveyed at the site was done so using stratified sampling and random sampling. The sample points are shown in Figure 3.01. In Table 1.1 that follows, there is a complete of the plants and trees found at the site. FLORA: Table 1- A Complete List of the Floral Species Found at the Vision City Project Site Species Common Name Species Scientific Name Wild